One of David Estlund’s key claims in Utopophobia is that theories of justice should not bend to human motivational limitations. Yet he does not extend this view to our cognitive limitations. This creates a dilemma. Theories of justice may ignore cognitive as well as motivational limitations—but this makes them so unrealistic as to be unrecognizable as theories of justice. Theories may bend to both cognitive and motivational limitations—but Estlund wants to reject this view. The other alternative is to find some (...) non-ad hoc way to distinguish cognitive from motivational limitations. I argue that this strategy will not work. Just as a person’s cognitive limitations may block her motives no matter how much she perseveres, so too motivational limitations may be genuine inabilities. Even ideal theories of justice must bend to even ordinary motivational limitations when they truly cause us to be unable to comply with requirements. (shrink)